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Background
On January 6, 1999, respondent sent petitioner a notice of
deficiency. In the notice, respondent determined a deficiency in
petitioner’s Federal income tax for the taxable 1996 year in the
amount of $2,838.
On January 9, 1999, petitioner received the aforementioned
notice of deficiency. However, petitioner never commenced an
action for redetermination in this Court.
On March 12, 2001, respondent sent petitioner a Final
Notice/Notice of Intent to Levy and Notice of Your Right to a
Hearing in respect of petitioner’s outstanding liability for
1996. Thereafter, on March 29, 2001, respondent received from
petitioner a Form 12153, Request for a Collection Due Process
Hearing. In the Form 12153, the only reason given by petitioner
why she disagreed with respondent’s proposed collection action
was “disagree with assessed balance”.
Petitioner’s request for a hearing was assigned to
respondent’s Appeals Office in Pittsburgh, Pennsylvania. During
the course of the administrative proceeding, petitioner raised no
issue other than her underlying tax liability for the assessed
deficiency. The Appeals officer advised petitioner of the
limitation set forth in section 6330(c)(2)(B) on challenging her
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Last modified: May 25, 2011